ASBG responded to the NSW EPA's Draft Landfarming: Technical Practice Notes citing the disproportionate emphasis on VOC emissions from such a miniscule source.
ASBG accepts that some landfarming practices may not well run and some controls may be required. However, the landfarming notes require treatability tests to be undertaken for apparently all landfarms. Where VOC emissions are considered by the EPA to be excessive they will need to be controlled using tents, greenhouse enclosures or covers. ASBG is concerned the testing and performance requirements are not specified and acceptance is at the consideration of the regulator.
ASBG calls for a more holistic approach where the notes consider the material to be treated - bio-degradable hydrocarbons - and assess each available and economically viable option. Clamping down on too hard landfarming is expected to simply transfer the problem to landfill or result in abandonment of remediation. Ideally the outcome should be to maximise environmental outcomes than to focus on one treatment type.
 ASBG's response to EPA's Landfarming Notes | 117 kB |
